The digital landscape is subjected to constant change as a result of new technologies, trends and on-going changes to legislation/laws. The latest change to impact the industry is Consent Mode v2, which is coming from Google as a result of increased privacy concerns from users and emphasis on GDPR compliance etc.
Google’s introduction of Consent Mode v2 was rather sudden, with the implications of failing to comply being rather vague. With such a big technical change being sprung upon users within a short timeframe, it’s likely that not everyone will have a chance to implement this into their website and by the March 2024 deadline.
Google’s Consent Mode (GCM) v2 is designed to integrate a website visitor’s given consent (from cookie banners/widgets) with Google’s own advertising and analytics tools, to allow them to dynamically adapt their behaviour. It exists to comply with tightening EU privacy laws and governing bodies, such as the DMA, since legislation requires gatekeepers such as Google to obtain explicit consent for the collection and use of European citizens' personal data.
GCM v2 introduces two new parameters to their existing ones of analytics_storage and ad_storage:
These new parameters are designed to enhance user privacy and to determine if personal data may be sent to Google based on user consent. Consent Mode can be implemented in two different modes, those being Basic and Advanced Consent Mode – which will be covered below.
Google have stated that Consent Mode v2 should be implemented, where relevant, by March 2024 and website owners operating within Europe would need to ensure changes are implemented in order to prevent any impact to other Google tools such as Google Ads and Google Analytics.
The exact implications of failing to implement GCM by this deadline is mostly unknown, however Google have suggested that it is required to continue using conversion measurement, ad personalisation and remarketing features.
Based upon this, it is a fair assumption that audience building and remarketing capabilities will be crippled (if not outright disabled) for the data collected from your digital properties. If you are running Shopping campaigns or are using audiences for targeting rather than just observation, then this should be a top priority for you. Even if you do not fully utilise audiences and remarketing features within your Google suite, it is still advised to get Consent Mode v2 in place to mitigate any potential impact on your GA4 or Google Ads data collection and performance – especially if you’re operating in or serving to users in the European Economic Area (EEA).
This is where Consent Mode has been implemented upon your site/Google properties, and data is collected only if the user grants consent. If cookies are declined, then Consent Mode signals will be sent to Google to indicate that this particular user cannot and will not be tracked. This is similar to how your traditional cookie banner would currently be operating, except with the addition of these signals being sent directly to Google.
In contrast to Basic Consent Mode, Advanced Consent Mode is when Consent Mode has been implemented, and data is collected for Google platforms from users when they grant consent and when they deny consent.
Google tags will continue to fire and collect data even if cookies are declined. In this case, data won’t necessarily be the most advanced and provide the highest levels of user insight as it instead relies on ‘cookieless pings’, but you will continue to collect data nonetheless. Google can then use this more anonymised data in its modelling, allowing it to recover some level of data for GA4 and Google Ads, even without user consent, allowing the tools to “fill in the gaps” of any missing data.
Whilst Advanced Consent Mode doesn’t use cookies when they have been declined by users, it is still worth considering the privacy implications of this and ensuring your Privacy Policy and any other legal texts on your website acknowledges this.
Alongside the sudden announcement of GCM v2, Google began to certify specific Consent Management Platforms (CMPs) to be Consent Mode v2 ready. If you do not currently have a cookie banner on your site, or if you are using a tool/CMP not found on this list (perhaps you are using your website builder’s own built-in option), then your simplest option is to identify a certified CMP tool which suits your needs and desired method of implementation.
You should consider things such as your use of Google Tag Manager (GTM) and whether they offer a method to manage things from within it, as this can allow you to maintain greater control over specific Google tags. Pricing is also a factor to consider, as CMP tools are not free and can have pricing models which may influence your decision based upon website visits or the size of your website.
It is worth checking whether the platform your website is built-upon offers a solution which is Consent Mode v2 compliant. For example, HubSpot recently launched a beta which can send Consent Mode signals to Google when using their built-in cookie banner tool. Some CMPs may not always give you the ability to pick between Basic or Advanced Consent Mode if you have a preference, so keep this in mind!
If you are currently using a CMP tool found within Google’s certified list, then you should seek out their documentation for implementing GCM v2. Implementation will differ between each platform, and setup of their Consent Mode v2 features may also vary. It is advised to identify your needs, seek out your CMP’s documentation and ensure you are testing along the way.
You can also talk to us to understand your options.
It should be noted that just because a website is correctly setup to send Consent Mode signals to Google, it does not automatically mean that it is completely compliant with all privacy laws. You should consider whether non-Google related tags are being fired on your website (think Meta/LinkedIn pixels etc.) and if they are withheld prior to consent, whether your Privacy Policy and other legal texts on your website encompass everything that is necessary, etc. Always seek the aid of a legal expert when you are unsure – the last thing you want is to receive a hefty fine!
Based upon your chosen method of implementation for your CMP and its GCM features, you may lose some level of control. For example, if you are currently adding GA4 tracking to your site via Google Tag Manager, then you have the freedom to edit this tag to change when or where it fires, and also the ability to easily add in any custom parameters, such as content groupings. If your new implementation involves GA4 being implemented through a direct integration with your CMP, then this level of control is likely lost.
As previously highlighted, there is often a cost associated with using a CMP platform. Alongside this, there is the time required to look through documentation and gain an understanding of how everything works, before then implementing and testing everything.
On a positive note, once implemented, you can have peace of mind that operations can continue without potentially losing vital data in GA4, Google Ads etc. and with Advanced Consent Mode you will have access to Google’s modelled data, to fill-in gaps in your data from users who declined cookies etc.
If you haven’t implemented a cookie banner on your site already, be warned that we’ve seen losses in traffic of up to 40% on some websites. This is because people are increasingly declining cookies due to a lack of trust in online privacy so if you make it easier to decline, a percentage of your audience will take this opportunity. There isn’t an easy way to bypass this but you can try to improve the way you collect first-party data to gain more knowledge about your audience and make better marketing decisions.
Google’s Consent Mode requirements have been quite a sudden introduction which require a fast turnaround to mitigate any negative effects. Whilst the exact implications this will have on your GA4 property and Google Ads account cannot be specified, this should definitely be high up on your to-do list – especially when dealing with users within the EEA, running shopping campaigns, or utilising created audiences.
Implementation will vary for each case, based upon needs and chosen CMP, but once setup, you will have peace of mind in knowing that your data or campaign performance shall not be negatively affected.
If you’d like to find out how Innovation Visual can help with your Consent Mode v2 implementation, reach out to us and our team of experts can help ensure your website and Google platforms are correctly tracking and collecting data.